Episode 305 -- Deep Dive into SAP FCPA Settlement
An amendment to South Africa’s Prevention and Combating of Corrupt Activities Act (PRECCA) in April 2024 has created a new criminal offense relating to the failure by members of the private sector or state-owned entities...more
Two recent court Foreign Corrupt Practices Act (FCPA) cases, a significant amendment to the Foreign Extortion Prevention Act (FEPA), and the new pilot whistleblower rewards program show that Anti-Corruption Enforcement...more
The ABB case, like most significant FCPA enforcement actions, sets important precedent and policy reminders. With time, and looking back, ABB gives companies with a prior criminal history a way forward to seek a fair...more
1. Is your country a member of the OECD Anti-Bribery Convention? Yes. 2. Is your country a member of any other bilateral or multilateral conventions on anti-corruption? Yes. South Africa is a member of the United Nations...more
The details of bribery schemes are invaluable for learning how criminals think – bribery always requires some scheme to transfer money from the organization to fund bribery payments to a government official(s). Compliance...more
The Justice Department’s new Corporate Enforcement Policy and the heightened enforcement and compliance expectations were put to the test in its announcement of a $315 million settlement of bribery charges with ABB, a...more
On 26 April 2021, the UK’s first sanctions under the Global Anti-Corruption Sanctions Regulations 2021 (SI 2021/488) (“the Regulations”) came into force. The Regulations are made under the Sanctions and Anti-Money Laundering...more
ANTICORRUPTION DEVELOPMENTS – Canadian Mining Company Settles with SEC over FCPA Charges – On March 26, Kinross Gold Corporation settled with the Securities and Exchange Commission (SEC) over its alleged failure to...more
Do you recall the boycott of South Africa from the 1970s and 1980s as a lexicon of the global fight against apartheid? The boycott extended from business to sporting events and everything in between. The campaign was one of...more
ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more
Massachusetts-based Alere Inc. will pay $13 million to settle charges alleging that the company bribed foreign officials and engaged in an accounting fraud, according to a Securities and Exchange Commission (SEC) Cease and...more
Compliance is a profession that requires multi-tasking – another profound grasp of the obvious. But in the multi-tasking world, some principles and strategies are more important than others. My colleague and...more
Leading the News - Burkina Faso: On October 1st, authorities in Burkina Faso said General Gilbert Diendere, the leader behind a recent coup attempt in the country, was in the custody of security forces. According to...more
The U.S. Securities and Exchange Commission (SEC) recently announced a settlement with Hitachi, Ltd. over allegations that the company sold shares in a South African subsidiary to a front company for the African National...more
The SEC continues to plug away at aggressive FCPA enforcement. This year, at least so far, the SEC has had a very successful year. The Hitachi case is a very interesting enforcement action for several major reasons. ...more
Earlier this week, the Securities and Exchange Commission (SEC) announced resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Hitachi Ltd (Hitachi). There were several interesting aspects to...more
Leading the News - Burkina Faso: On September 17th, U.S. National Security Advisor Susan Rice condemned the unconstitutional seizure of power by elements of the Presidential Security Regiment in Burkina Faso and...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month with links to primary...more
Welcome to the April 2015 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month in anticorruption developments, Canadian transportation giant faces scrutiny for alleged bribery in South...more